CBAM Reporting Service

CN code and threshold analysis, embedded emissions calculation, CBAM verification preparation, and data support for EU importers, compliant with the EU's 2026 definitive regime — end-to-end.

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Last regulatory check: 27 July 2026 · Based on the 2026 definitive regime and published secondary legislation.

What is CBAM Reporting?

CBAM (Carbon Border Adjustment Mechanism) is an EU carbon regulation that will enter its definitive regime as of 1 January 2026. The legal declaration, purchase of certificates, and submission obligation lie with the authorised CBAM declarant in the EU. Producers/exporters in Turkey, however, play a critical role in preparing product and facility-based embedded emissions data, calculation methodology, verification where necessary, and sharing data with the importer.

CBAM applies not to an entire sector, but to specific CN codes listed in Regulation (EU) 2023/956 Annex I. Therefore, the first step is to check the current CN codes of the exported products and the annual import volume of the EU importer, rather than just the company name.

50-tonne annual thresholdThis is the cumulative net mass threshold per EU importer for goods in the iron and steel, aluminium, cement, and fertiliser sectors. Imports up to 50 tonnes may benefit from a mass threshold exemption.

Electricity & hydrogenThese are exceptions to the 50-tonne mass threshold. For imports of these goods, CBAM authorisation and related rules apply regardless of quantity.

First annual declarationThe current deadline for the first CBAM declaration covering 2026 imports and the submission of corresponding certificates is 30 September 2027.

Official basis: consolidated CBAM Regulation in force and European Commission CBAM communication/FAQs page.

Which Products Are Covered by CBAM?

The current core scope of the definitive regime is related to six product groups; however, the obligation is determined by the CN code of each product within Annex I.

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Iron and SteelIron and steel and certain derivative products covered by Annex I

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CementCovered clinker and cement CN codes

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AluminiumCovered raw and processed aluminium goods

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FertiliserCovered fertilisers and related chemical products

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ElectricityElectricity imports; 50-tonne mass threshold does not apply

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HydrogenHydrogen imports; 50-tonne mass threshold does not apply

⚠️ Downstream expansion not yet definitively in force: In December 2025, the European Commission proposed adding approximately 180 steel/aluminium intensive downstream products to the scope from 1 January 2028. The Council adopted its negotiating position on 12 June 2026; the legislative process continues with the European Parliament. Therefore, the phrase “definitively included in scope” should not be used for products such as machinery, white goods, automotive parts, etc.

Council's 12 June 2026 status update.

What Does Our CBAM Service Cover?

We conduct the process according to current roles in EU legislation and the calculation methodology. ISO 14064-1 can provide a supporting infrastructure for corporate greenhouse gas inventories; however, the legal methodology for CBAM embedded emissions calculation must be established according to Commission Implementing Regulation (EU) 2025/2547 and related CBAM secondary legislation.

CN Code, Scope, and 50-Tonne Threshold Analysis

We compare the current CN codes of exported products with CBAM Annex I; we prepare a checklist for the EU importer regarding the 50-tonne annual mass threshold, electricity/hydrogen exemption, and authorised declarant status.

Initial scope analysis

CBAM System Boundaries and Data Map

According to 2025/2547, we define the system boundaries, production processes, precursors, and direct/indirect emission components to be included in accordance with the legislation for the relevant aggregated goods category. Since the scope of indirect emissions can vary by product, we do not generalise as “all Scope 1 + Scope 2”.

Methodology: EU 2025/2547

Actual or Default Value Selection

We compare the Commission's definitive period default values with the availability of actual data from the facility. If actual values are chosen, the total embedded emissions data provided by the producer must be verified in accordance with CBAM rules. Choosing actual values may create an advantage if they are lower than default values; this outcome is calculated on a facility-specific basis.

Actual / Default decision support

CBAM Verification Preparation and Coordination

If actual emissions data is to be used, verification is carried out by a verifier appropriately accredited for CBAM verification activities. Organisations authorised to grant CBAM verifier accreditation are national accreditation bodies of EU member states; after the inclusion of the CBAM Regulation within the scope of the EEA Agreement, the competent national accreditation bodies of the relevant EEA countries may also apply. Verification bodies established in third countries like Turkey may apply to a suitable EU or applicable EEA national accreditation body offering CBAM accreditation services. General greenhouse gas verification, ISO 14065, or similar accreditations obtained from TÜRKAK alone do not constitute “CBAM accredited verifier” status.

CBAM accreditation framework

O3CI — Third Country Installation Operator Data Sharing

We provide registration, data preparation, and operational control support for installation operators in Turkey to share their facility and emissions data with declarants in the EU using the O3CI (Operators of Third Country Installations) module within the CBAM Registry.

CBAM Registry / O3CI

Data Delivery to EU Importer and Annual Cycle

We prepare the necessary emissions information in a format suitable for submission to the importer, based on verified actual data or an appropriate default value approach. The first annual CBAM declaration for 2026 imports and certificate submission is due by 30 September 2027; certificate purchases to cover 2026 imports begin from February 2027.

First annual declaration: 30 Sep 2027

Methodology: Commission Implementing Regulation (EU) 2025/2547 · Verification: European Commission — CBAM Verification · O3CI: CBAM Registry and Reporting.

How Are 2026 CBAM Certificate Prices and Actual Costs Calculated?

Calculating CBAM costs solely as “product tCO₂ value × ETS price” is not accurate. The certificate obligation of the authorised declarant is affected by factors such as the actual/default embedded emissions data used, free allocation adjustment, relevant CBAM benchmarks, and, if conditions are met, the carbon price actually paid for the same emissions in the country of origin.

2026 CBAM certificate prices published by the European Commission
Period	Official price	Status
2026 Q1	75.36 €/tCO₂	Published on 7 April 2026
2026 Q2	75.28 €/tCO₂	Published on 6 July 2026

Important: These prices alone do not represent the “CBAM cost per tonne of product”. In 2026, the CBAM free-allocation adjustment continues; the relevant EU ETS CBAM factor for 2026 is 97.5%. This 97.5% rate is not the CBAM cost rate. It refers to the retention of 97.5% of the relevant EU ETS free allocations in 2026, or in other words, a 2.5% reduction in free allocations covered by CBAM in the first year. Detailed free allocation adjustment calculation is performed under Commission Implementing Regulation (EU) 2025/2620.

For 2026, the Commission publishes quarterly prices. From 2027, prices will be calculated weekly. The purchase of certificates for 2026 imports on the common central platform begins from February 2027.

European Commission — CBAM certificate prices · EU 2025/2620 — free allocation adjustment.

Responsible® Programme: 2026 Current Support Framework

The Ministry of Trade's Green Deal Adaptation Project Support – Responsible® Programme may support eligible consulting expenses within the approved sustainability roadmap for eligible manufacturing-exporter companies.

2026 official upper limit: 50% support rate for consulting expenses, for a period of 5 years, and a total upper limit of 17,640,256 TL. Benefiting from the programme and the eligibility of each expense is not automatic; company eligibility, the Responsible® process, the approved roadmap, the list of consultancies to be supported, and the Ministry's assessment are taken into account.

The current information on the programme states that companies applying must have exported 300,000 USD or more in total in the last three calendar years preceding the current year and be manufacturing/exporting companies. Work related to CBAM should be evaluated to the extent that it is compatible with the approved project and support scope; a guarantee that “every CBAM consultancy automatically receives a grant” is not given.

Ministry of Trade — Responsible® Programme · 2026 official support upper limits.

Digital Data Management with Carboniva

Managing the energy, production, raw material, and emissions data required for CBAM in a structured data infrastructure simplifies the annual reporting cycle. Carboniva is Europecarbon's digital carbon management platform; its use is not mandatory under CBAM legislation.

💻 What can you do with Carboniva?

Track emissions data centrally, version annual data sets, and utilise the same data infrastructure for corporate carbon footprint and CBAM work.

Review Carboniva Plans →

Why Europecarbon?

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Current CBAM Methodology

We establish the 2026 definitive regime calculation based on 2025/2547 and related default/benchmark regulations.

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CN Code + Emissions Together

We assess product scope not just by sector name, but also by Annex I CN code and the EU importer's threshold status.

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Verification Preparation

For actual data preference, we prepare the dossier according to CBAM-specific accreditation and verification requirements.

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O3CI Data Flow

We provide operational support for third-country installation operators in the data sharing process via the CBAM Registry.

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Official Support Control

We evaluate Responsible® support on a project-by-project basis, without guarantees, according to current official limits and eligibility conditions.

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Digital Data Infrastructure

With Carboniva, we facilitate systematic maintenance of annual emissions data and subsequent period updates.

Integrated Sustainability Services

The CBAM data infrastructure, by separating correct boundaries and methodologies, can also support other carbon and sustainability initiatives.

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Corporate Carbon Footprint

ISO 14064-1 based corporate greenhouse gas inventory. It does not replace the CBAM methodology, but supports its data infrastructure.

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GRI Sustainability Reporting

Support for sustainability reporting according to GRI standards.

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EcoVadis Consulting

Supply chain sustainability assessment and evidence file support.

🚀 Free CBAM Pre-Assessment

Share your product CN codes, sector, and EU export structure; let's conduct the initial scope check together.

Contact Us Now

📞 Call us directly:
+90 216 573 64 04
carbon@europecarbon.com

Frequently Asked Questions

Who prepares the CBAM report; the EU importer or the producer in Turkey?

The legal declaration and certificate submission obligation for CBAM lies with the authorised CBAM declarant in the EU. The producer or exporter in Turkey, however, plays a critical role in providing facility and product-based embedded emissions data, the method used, and, if actual emissions are chosen, the necessary verified data to the importer. Facility and emissions data can be shared with declarants in the EU via the O3CI module.

How is the 50-tonne CBAM threshold applied?

In the 2026 definitive regime, the single annual mass threshold is 50 tonnes net mass and is assessed cumulatively per EU importer for CBAM goods in the iron and steel, aluminium, cement, and fertiliser sectors. Importers above the threshold are subject to CBAM authorisation and related obligations. Electricity and hydrogen imports are exempt from the 50-tonne mass threshold and are subject to CBAM rules regardless of quantity.

Can we use EU default values?

Yes. In the definitive regime, the authorised CBAM declarant may use the Commission's default values or actual emissions values, subject to the conditions in the regulation. If actual emissions values are preferred, the third-country producer must provide the total embedded emissions data, and this data must be verified in accordance with CBAM rules. Financial obligations may decrease if the actual emissions value is lower than the default value; however, it cannot be guaranteed that this will automatically be lower for every facility.

Is TÜRKAK accreditation alone sufficient for CBAM verification?

No. Organisations authorised to grant CBAM verifier accreditation are national accreditation bodies of EU member states; after the inclusion of the CBAM Regulation within the scope of the EEA Agreement, the competent national accreditation bodies of the relevant EEA countries may also apply. Verification bodies established in third countries like Turkey may apply to a suitable EU or applicable EEA national accreditation body offering CBAM accreditation services. General greenhouse gas verification, ISO 14065, or similar accreditations obtained from TÜRKAK alone do not constitute “CBAM accredited verifier” status.

How is the 2026 CBAM certificate price determined and when is the first declaration due?

For 2026, the European Commission publishes four quarterly CBAM certificate prices; prices are based on the weighted average of EU ETS auction closing prices in the relevant quarter. The Q1 2026 price was published as 75.36 Euro/tCO₂, and the Q2 price as 75.28 Euro/tCO₂. The purchase of certificates to cover 2026 imports begins from February 2027. The deadline for the first annual CBAM declaration covering 2026 imports and the submission of corresponding certificates is 30 September 2027.

Can the Ministry of Trade's Responsible® support be used for CBAM activities?

Under the Green Deal Adaptation Project Support – Responsible® Programme, consulting expenses within the framework of approved sustainability roadmaps and supported consulting areas for eligible companies can be supported at a rate of 50%, for five years, and up to a total upper limit of 17,640,256 TL for 2026. Support for a CBAM-related expense is not automatic; company eligibility, the approved project, the list of consultancies to be supported, and the Ministry's assessment must be considered together.

Official CBAM Resources

The regulatory and 2026 implementation information on this page is based on the following primary sources.

European Commission — CBAM Regulation (EU) 2023/956 — current text EU 2025/2547 — embedded emissions methodology EU 2025/2621 — definitive-period default values CBAM legislation & guidance CBAM verification & accreditation CBAM Registry / O3CI CBAM certificate prices T.R. Ministry of Trade — EU CBAM Responsible® Programme

Last content/regulatory check: 27 July 2026.

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Güncel · 130 Soru

CBAM (SKDM) Sıkça Sorulan Sorular — Türkçe

Avrupa Komisyonu'nun “CBAM Questions and Answers” dokümanındaki tüm soruların Türkçe derlemesi. Bilgilendirme amaçlıdır; bağlayıcı metin AB Resmî Gazetesi'nde yayımlanan mevzuattır.

130 soru

Genel

CBAM Beyanları ve Kayıt Sistemi

CBAM Sertifikaları ve Yükümlülük

Gömülü Emisyon Hesaplama Metodolojisi

Akreditasyon ve Doğrulama

Sektöre Özgü Kurallar

Gümrük İşlemleri

Kaynak: Avrupa Komisyonu, CBAM Questions and Answers (27 Mayıs 2026). Türkçe çeviri ve derleme: EUROPECARBON.